PPS5 and Listed Building Protection

Jonathan Taylor

The last UK government's proposed reform of heritage protection in England was derailed by the financial crisis, leaving no parliamentary time available for the new Heritage Protection Act. Nevertheless, aspects of the proposals which did not require an act of parliament were pushed through by the Labour government in March 2010, just before the election. This saw the replacement of PPGs15 and 16, the planning policy 'guidance' which directed the protection of the historic built environment and archaeology in the country, with PPS5, a planning policy 'statement' which achieves much the same result but in a very different way, and a 'planning practice guide' which gives some further detail.

PPG15 - September 1994
Planning Policy Guidance 15: Planning and the Historic Environment
Department of National Heritage

Table: old guidance and new policy

PPS5 - March 2010
Planning Policy Statement 5: Planning for the Historic Environment
PPS5 Planning for the Historic Environment: Historic Environment Planning Practice Guide
Department for Communities and Local Government

PPG16 - November 1990
Planning Policy Guidance 16: Archaeology and Planning
Office of the Deputy Prime Minister

PPS5 is written as guidance to local authorities. Applicants for listed building consent will find that listed buildings are protected much as before, although some of the terminology has changed.


1. Heritage assets

One of the key aims of heritage protection reform was to unify the separate legislation protecting archaeology and the historic environment, simplifying the system. A new term was introduced to encompass historic buildings, monuments and other features; 'heritage assets'. Listed buildings and scheduled monuments are now 'designated heritage assets', as are world heritage sites, protected wreck sites, registered parks and gardens, registered battlefields and conservation areas. The levels of protection which apply to each of these remain unchanged, since the relevant acts of parliament remain the same.

2. Significance

According to the Planning (LB&CA) Act, the focus for control over works to a listed building is their effect on the architectural or historic 'interest' of the building, thus:

No person shall execute or cause to be executed any works for the demolition of a listed building or for its alteration or extension in any manner which would affect its character as a building of special architectural or historic interest, unless the works are authorised.

Planning (Listed Buildings and Conservation Areas) Act 1990
Section 7

In PPS5, however, the term used is 'significance', as used by ICOMOS in the internationally agreed Burra Charter. This is defined here in PPS5 as: 'The value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic.' It thus encompasses the concept of interest, and relates back to the act.

3. Principles of approach: understanding significance

Given its much broader scope than either of the two PPGs it replaces, it is surprising to find that the PPS is much shorter than either of them. It achieves this largely by omitting all the examples included in the appendices and by focussing on the need to understand the significance of the heritage asset and the impact of the proposals on this significance:

Local planning authorities should require an applicant to provide a description of the significance of the heritage assets affected and the contribution of their setting to that significance. The level of detail should be proportionate to the importance of the heritage asset and no more than is sufficient to understand the potential impact of the proposal on the significance of the heritage asset.

 PPS5, Policy HE6

The statement goes on to require that the significance of the heritage asset is 'assessed using appropriate expertise where necessary', including desk-based assessment where archaeological interest is concerned, and field evaluation if necessary.

4. Climate change

While only two percent of buildings in England are listed (and less than 0.08 percent at grades I and II*), many more could be termed heritage assets, as there are almost 9,000 conservation areas in England, and over 20 per cent of our building stock predates 1914. As a result, the new PPS applies to a significant proportion of our building stock, and the contribution made by these buildings to climate change must be taken into account. Policy HE1 of PPS5 outlines the principles. It recognises that 'keeping heritage assets in use avoids the consumption of building materials and energy and the generation of waste from the construction of replacement buildings'. It encourages finding solutions that do least harm to 'the significance of the heritage asset and its setting', and it stresses the need for a balanced approach, weighing impact on the significance of the heritage asset affected against 'the public benefit of mitigating the effects of climate change'.

How 'public benefit' is to be measured is not specified in HE1. For example, Grade I and II* buildings represent a tiny proportion of our building stock, so upgrading these buildings would produce relatively little public benefit. On the other hand, it could be argued that upgrading a large building would produce greater public benefit than upgrading a small one, irrespective of its grade of listing. Where the PPS throws up areas of uncertainty such as this, 'The Government's Objectives' which preface the policies provide some clarification, with its clear emphasis on significance, as outlined below.


The section entitled 'The Government's Objectives' is an important component of the PPS because it places the policies that follow in their context, reducing the risk of misinterpretation. These state why the historic environment and its heritage assets are considered to be important, and how they are to be conserved. Here it explains that 'the Government's overarching aim is that the historic environment and its heritage assets should be conserved and enjoyed for the quality of life they bring to this and future generations'. One objective is thus; 'to conserve England’s heritage assets in a manner appropriate to their significance by ensuring that decisions are based on the nature, extent and level of that significance'.

Policy HE9 provides the crux of protection for listed buildings:

There should be a presumption in favour of the conservation of designated heritage assets and the more significant the designated heritage asset, the greater the presumption in favour of its conservation should be. …Substantial harm to or loss of a grade II listed building … should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, including …grade I and II* listed buildings … should be wholly exceptional.

To conclude, although the legislation protecting listed buildings remains unchanged, there has been a significant change in terminology and emphasis, and PPS5 needs to be read carefully by all applicants for listed building consent. The good news is that PPS5 is a lot shorter than PPGs 15 and 16.



This article was written specifically for this website in May 2010


JONATHAN TAYLOR is the editor of The Building Conservation Directory and a co-founder of Cathedral Communications Limited. He studied architectural conservation at Heriot-Watt University, Edinburgh and has a background in architectural design, conservation and urban regeneration.

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